This is part one of a multi-part series on emergency equipment, which will cover emergency fixture requirements in the OSHA regulations for worker safety, the industry standard for emergency fixtures, and the industry standard for temperature actuated mixing valves for emergency fixtures and design discussion.
The OSHA Code of Federal Regulations OSHA 29 CFR 1910.151 (c)
Emergency showers and eyewashes are required by the U.S. Department of Labor where workers can be exposed to hazardous materials in the workplace. The OSHA Code of Federal Regulations, OSHA 29 CFR 1910.151 (c) requires suitable facilities for quick drenching or flushing of the eyes and body to be provided within the work area for immediate emergency use.
Employers should always be aware of hazardous locations where employees should be required to wear personal protective equipment (PPE).
Emergency shower and eyewash equipment has evolved and has been available for a long time, but it was not until 1970, when OSHA was created, that emergency equipment and PPE became mandatory for workers. Prior to 1970, it was voluntary compliance by mostly larger employers who were concerned about worker safety and could afford safety equipment training. Since 1970, OSHA has adopted several regulations that refer to the use of emergency eyewash and shower equipment. The primary regulation contained in the Code of Federal Regulations (CFR) is as follows:
29 CFR 1910.151. (c) Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.
American National Standard Institute (ANSI) Z358.1
The International Safety Equipment Association (ISEA) developed the industry standard for emergency shower and eyewash fixtures in accordance with ANSI requirements. The document is titled: ANSI/ISEA Z358.1-2014 - American National Standard for Emergency Eyewash and Shower Equipment. It was originally adopted in 1981 with revisions in 1990, 1998, 2004 and 2014. The ANSI/ISEA Z358.1 document is the industry standard, which outlines the specific requirements for emergency eyewash and shower equipment with respect to: installation, location, testing, performance, maintenance, training and use.
Plumbing code requirements
The ANSI Z358.1-2014 standard was added to the model codes a couple of cycles ago. The codes now require compliance with the ANSI Z358.1-2014 standard when emergency fixtures are installed. In the last code cycle, which will take effect in 2018, the International Plumbing Code approved a change to require when emergency equipment is installed, the water supplied to the emergency fixtures shall be supplied through a device conforming to ASSE 1071 titled: Performance Requirements for Temperature Actuated Mixing Valves for Plumbed Emergency Equipment.
OSHA workplace inspections
Occupational safety inspections are typically scheduled to inspect workplaces on a regular basis by OSHA inspectors. They may occur randomly without prior notice, or they may occur due to a complaint. They almost always occur due to a workplace injury accident.
OSHA incident investigation
I was an expert witness for a workplace injury where a worker was burned on the face and chest by a burner assembly in a factory. He ran to the emergency shower and eye wash station to cool his burns. When he activated the emergency equipment, he was sprayed with black, slimy, bacteria-laden water flowing from the shower and eyewash. He didn’t notice it at first because he was blinded by the burns. He looked down to see thick, black liquid flowing on the floor. He was overwhelmed by a sewage smell. The liquid slowly changed from black to orange. His skin was burned and sloughing off in some places as the bacteria laden water flowing from the emergency fixture flushed bacteria and rust into his open burn wounds.
The water had been sitting stagnant in the pipes for years, and the facility had not been flushing their emergency equipment. The building owner was fined a significant amount of money by OSHA for multiple violations. In addition to the OSHA fine, there was a personal injury lawsuit brought by the injured worker. The overall result was fines and litigation costs in the millions of dollars. This clearly demonstrates the need for regular flushing of emergency fixtures.
The penalties can be as little as a warning if OSHA notices an unsafe condition during a routine inspection. The penalties can include a monetary fine or even a facility shutdown if the violation is a repeat, or if someone is injured and the facility is deemed unsafe. Employers, design professionals, contractors and owners can share in the liability, and they can be affected by fines and possible litigation for not complying with the OSHA requirements for emergency fixtures.
Emergency equipment selection
1. Emergency equipment should be carefully selected to address the level of hazard exposure to workers and how many individuals will be affected while being cognizant of the regulatory requirements and standards for compliance:
a. Emergency showers
b. Emergency eyewash (and face wash) stations (eye/face wash stations alone may not comply with suitable facilities for flushing and drenching in all cases.)
c. Combination emergency shower eye/face wash stations. (Combination units must be arranged to allow for simultaneous use of both the shower and the eye/face wash.)
d. Self-contained eyewash equipment and flexible, handheld hose equipment is generally considered supplemental and may not meet the primary requirement for suitable flushing facilities of the eyes, face and body simultaneously.
2. Many facilities have decided to use sink- or deck-mounted eyewashes and/or flexible drench hoses in lieu of combination shower and eye/face wash units. It should be noted that the new code requirements for ASSE 1071 mixing valves will be problematic for sink faucet-mounted equipment because the water temperature to emergency equipment is required to be supplied through an ASSE 1071 device, which limits the maximum temperature to no more than 100 F. If the faucet is intended to supply hot water in excess of 100 F, there will be problems complying with hot water and tepid water requirements. The emergency fixtures are required to remain open upon initial single-step operation until they are manually turned off, and they are required to be operable with a single hand when the user may have distorted vision. Sink-mounted units are basically a liability, and proper consideration should be given to the possibility of eye damage if the temperature of the water flowing from the sink can exceed 100 F.
The basics of emergency showers and eyewashes
When an emergency fixture is used, its purpose is to provide flushing fluid to cool the skin, dilute any hazardous chemicals, and flush the hazardous materials from the skin. The velocity/pressure is important and should be low enough to be non-injurious to the eyes or skin. If the pressure is too high, water will emit from the fixture at a high velocity and be uncomfortable on burned or damaged skin or in the eyes.
Flow regulators and verification of proper shower patterns and eyewash streams are important. Emergency fixtures should be located within 10 seconds walking distance of a hazard and on the same floor level. (The average brisk walking pace is 5.5/per second, which would equate to about 55 feet in 10 seconds.)
I have participated in the discussions of the working group for emergency fixtures in past revisions. One of the difficult areas of discussion was determining how close the emergency equipment needed to be to the hazard. In the past, using an actual dimension proved problematic when a fixture was a few feet beyond the dimension printed in the standard, then clearly it was in violation. The working group developed the language to include time, not distance. Ten seconds was chosen as a reasonable time to get from a hazardous location to an emergency fixture, and it was included as a recommendation in the appendix in lieu of a specific distance to allow for some flexibility for fixture locations.
The path of travel from the hazardous area to the emergency fixture should be free of obstructions. The area around an emergency fixture, and the path to the fixture, should also be well-lit so the user can clearly see where they are going and see the emergency fixture. Emergency fixtures should be identified with a highly visible and brightly colored sign. The delivered flushing fluid temperature is required to be “tepid” (not “tempered”).
Tepid water vs tempered water
“Tempered water” is defined in the plumbing codes as follows: “Tempered Water — Water having a temperature range between 85 F and 110 F.” Since tempered water was defined in the plumbing codes with a specific temperature range that is too hot for use in emergency fixtures, the term could not be referenced in the emergency fixture standard. The term “tepid water” was chosen, which has the following definition in a dictionary:
“Tepid — Moderately or slightly warm; lukewarm.”
This definition was more appropriate, and this term was used to define the emergency fixture water temperature. In the appendix, the temperature range of 60 F to 100 F was used, however, my testing of water temperatures flowing from a plumbing fixture at temperature below 70 F felt too cold. Therefore, a design professional should install a temperature actuated mixing valve and make sure it is set at a temperature high enough to not cause hypothermia or discomfort, which would not encourage flushing in the fixture for the 15-minute duration.
It should also be noted that temperatures over 100 F could cause damage to the eyes. Ideally the temperature should be set to about 80 F, plus or minus 10 degrees, as a design condition. Compliance with 60 F to 100 F will satisfy OSHA, but in order to encourage use for the full 15-minute duration, the minimum temperature should be about 70 F. More studies need to be done on this subject, because no hypothermia test exists for water flowing over someone. All hypothermia tests seem to be associated with the Navy and people being submerged in cold water that can form a boundary layer near the skin. Hypothermia in flushing water can occur sooner, as the flushing fluid continually flows across the body and removes body heat. Maybe some federal research money can be directed toward this effort.
1. Tepid water is defined in the appendix of the standard as water between 60 F and 100 F.
2. The model codes are now starting to require tepid water to be delivered to all emergency fixtures through mixing valves conforming to ASSE 1071.
3. Use of tepid water in the mid-to-upper range of the tepid water range helps prevent hypothermia.
4. Tepid water helps cool chemical burns.
5. Flushing with tepid water helps prevent chemical absorption or continued chemical burn exposure. (Ideally a facility owner should have a safety expert assess the proper final temperature set point for the ASSE 1071 valve for a given location.)
6. Tepid water helps encourages safety equipment use for the full 15-minute duration.
1. Privacy screens encourage disrobing of chemical soaked clothes which minimize chemical exposure.
2. Heated environmental enclosures encourage the use of fixtures in cold climates.
Safety features in ASSE 1071 Mixing Valves for Plumbed Emergency Equipment
Every emergency fixture thermostatic mixing valve should have the following redundant safety features:
1. The cold water should bypass the mixing valve and provide full cold water flushing flow upon a hot water failure, or any other abnormal condition
2. The valve should be sized to provide accurate control of the tepid water when only the eyewash is in use. In system designs using one large valve with an emergency fixture loop, it promotes improper temperature control for uncirculated tepid water systems and bacteria growth from stagnant water conditions.
3. Full-flow cold water bypass in the event of blocked flows
Other water supply temperature concerns
Water supplies can get very hot or cold if the emergency fixture water lines are exposed to extreme temperatures outdoors, or high temperature process piping systems or equipment indoors. Extreme temperatures can create a condition where the water temperature sitting in the pipe absorbs ambient heat by radiation or convection and can be very hot when flowing from the emergency fixture.
In some southern locations, I have performed inspections of emergency fixtures in industrial facilities where pipes were exposed to sunlight and running beside high-pressure steam mains. In other cases, the pipes ran over boilers and near boiler stacks that allowed heat to transfer to the emergency fixture water, causing the water flowing to the fixtures to be as hot as 124 F. It’s important to avoid heat sources when routing the emergency fixture water supply. In some northern climate locations, cold water flowing from the emergency equipment dropped to well below 40 F after several minutes of flowing the fixture. Fluid flushing temperatures of 60 F is very uncomfortable and does not encourage adequate flushing of chemicals. Lower temperatures can cause pre-mature termination of the use of the emergency fixture or hypothermia in a short period of time.
Emergency equipment design
The architect, safety consultant, engineering staff, emergency equipment providers and design engineer should work together to review of each application and select the proper type of combination emergency shower and eyewash equipment and supplemental equipment if the owner deems it necessary. They should also identify the location immediately adjacent to the identified hazards, determine the size, type and location of the water heating equipment, available utilities and the size and type of emergency fixture temperature actuated mixing valve with a cold-water bypass that complies with ASSE 1071 Temperature Actuated Mixing Valves for Plumbed Emergency Equipment. (Mixing valves that comply with ASSE 1017 Performance Requirements for Temperature Actuated Mixing Valves for Hot Water Distribution Systems are not appropriate for emergency fixture applications because they do not limit temperatures to 100 F, and they do not have a cold-water bypass.)